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There are other sections, however, where the word “remaining”
is used in a different context as a copula12 or linking verb. When
used as a copula the word “remaining” links the word that precedes
it to the word that follows it;13 e.g., the income remaining
undistributed. In those sections, the word “remaining” means that
the preceding word “continues to be unchanged” in the “form,
condition, or status” described by the word that follows. We
believe that within the context of the effective date provisions of
section 6015 a tax liability “remaining unpaid” on or after July
22, 1998, means that the liability continues to be unpaid after
July 22, 1998.
The applicability of section 6015 to the issue before us thus
turns on the meaning of the word “unpaid”. The primary definition
11(...continued)
application of subsection (a)”); sec. 7608(c)(3) (“such proceeds or
the balance of such proceeds remaining at the time”); sec. 9008(f)
(“moneys remaining in the account * * * moneys so remaining”); sec.
9038(b)(3) (“that portion of any unexpended balance remaining in
the candidate’s accounts”).
12 Copulas are verbs that link a predicate (adjective, noun,
etc.) to the subject. I Curme, A Grammar of the English Language,
par. 12.3, 66 (1986). Copulas often indicate a state, continuance
in a state, or entrance into a state. Id. par. 12.3, 68. The verb
“remain” is among the most common copulas and indicates a
continuance in a state. II Curme, A Grammar of the English
Language, par. 6.B, 27-28.
13 See, e.g., sec. 411(b)(1)(A) (“benefits * * * shall be
treated as remaining constant”); sec. 9704(i)(1)(B) (“the expenses
accrued (and remaining unpaid)”); sec. 4942(a) (“the amount of
such income remaining undistributed at the beginning of such second
(or succeeding) taxable year”); sec. 7448(j)(3) (“Any accrued
annuity remaining unpaid”).
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